Vaidik, J.
Case Summary
Kurt Williams appeals the small-claims court’s judgment for Karin Kirch. He argues that the judgment is contrary to law and that the court erred in ordering him to pay attorney’s fees. We affirm on both issues.
We also take this opportunity to remind pro se litigants and attorneys of the dangers of using artificial intelligence (AI) to conduct legal research. Generative AI can produce citations to non-existent authorities, and we caution litigants to verify citations before including them in briefs.
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III. Warning regarding AI-generated citations
We must address a troubling aspect of Williams’s brief. He cites several “cases” in his opening brief that do not exist. See Appellant’s Br. pp. 11 (“Davis v. United States, 569 U.S. 764 (2013)”), 12 (“Bourne v. Scarborough (IN 2014)”), 17 (“In re Marriage of Nigh, 2016 IL App (5th) 150274”). As Kirch suggests, this may be the result of the use of “generative artificial intelligence,” which can produce fictitious case citations. See Mid Cent. Operating Eng’rs Health & Welfare Fund v. HoosierVac LLC, No. 2:24-cv-326, 2025 WL 1511211, at *1 (S.D. Ind. May 28, 2025). Despite Kirch identifying these nonexistent citations, Williams provides no explanation for them in his reply brief.
Citations to fictitious, AI-generated authority is a growing problem nationwide. Courts have sanctioned both attorneys and pro se litigants for including them in briefs. See id. at *2; Kruse v. Karlen, 692 S.W.3d 43 (Mo. Ct. App. 2024), reh’g denied, trans. denied. But because Kirch does not request any sanction or relief for this conduct, we find it sufficient to admonish Williams for citing fictitious cases in his brief. We caution attorneys and pro se litigants alike against using AI to conduct legal research without independently verifying the citations generated. Judges must be able to rely on the authenticity of the authorities cited by the parties to make just decisions.
Affirmed. Tavitas, J., and Felix, J., concur.